Non-compliant marking

Non-compliant marking is a label, symbol, QR code, or CE mark that is missing, incorrect, misleading, illegible, or placed in the wrong location, judged against Article 13, Annex VI, and the conformity provisions. Non-compliance can arise from artwork error, a changed battery value that was not carried into the label, a damaged or faded marking, or a QR code that resolves to the wrong record. The finding must be recorded with the battery identifier or model, the marking version, the defect, and the date found. The corrective action must state whether affected batteries are relabelled, withdrawn, or otherwise corrected, and the recheck must test the corrected marking. A finding that is noted but never corrected remains open.

Non-compliant marking means marking that does not meet the applicable labelling, marking, or CE marking requirements. The scope covers labels, symbols, QR codes, and CE marking for the battery model and period stated.

What is the legal frame for this marking?

Non-compliant marking is a physical marking duty and a record duty at the same time. A market surveillance checker finding a wrong capacity label on a batch should work from the current consolidated text and check whether an implementing act on harmonised label specifications has entered into force, since Article 13 sets some dates by reference to that act. A batch with a capacity label that states a value from an earlier model should be held, the affected identifiers listed, the artwork corrected, and the relabelled batch rechecked by scanning and visual inspection before release.

How are content, placement, and legibility checked?

Content asks whether every required element for non-compliant marking is present and correct for the battery category. The finding record, corrective action plan, and recheck log should include a photograph or a retained sample label, the artwork version, and the approval date, tied to the battery model. Market surveillance authorities can require corrective action, withdrawal, or recall under Regulation (EU) 2019/1020, and the operator record should show cooperation, the measures taken, and the dates, without overstating the outcome of a pending case.

How does category decide content?

Category decides content. For non-compliant marking, the record should state the category as defined in Article 3, list the label elements that apply to that category, and list the elements that do not apply, with the reason. A market surveillance checker finding a wrong capacity label on a batch should be careful where a battery could fall into more than one description, and should record the reasoning for the category chosen. A batch with a capacity label that states a value from an earlier model should be held, the affected identifiers listed, the artwork corrected, and the relabelled batch rechecked by scanning and visual inspection before release.

How are measurement and wording recorded?

For non-compliant marking, a capacity value, a chemistry statement, or a duration value should name the test method, the conditions, and the unit, so the same battery tested again gives a comparable result. The finding record, corrective action plan, and recheck log should include the test report or the calculation sheet, the date, and the person or function that approved the value. Market surveillance authorities can require corrective action, withdrawal, or recall under Regulation (EU) 2019/1020, and the operator record should show cooperation, the measures taken, and the dates, without overstating the outcome of a pending case.

What sits behind the marking in the documentation?

For non-compliant marking, the declaration should identify the battery, the Regulation, and the conformity assessment procedure followed, and the technical documentation should support each marked claim. A market surveillance checker finding a wrong capacity label on a batch should check that the declaration date, the battery model, and the marking version are consistent, and that a change to the battery that affects conformity leads to a review of the documentation. A batch with a capacity label that states a value from an earlier model should be held, the affected identifiers listed, the artwork corrected, and the relabelled batch rechecked by scanning and visual inspection before release.

How is a marking checked line by line?

For non-compliant marking, a checker should compare the physical marking, the QR code destination, the passport entry where a passport applies, the declaration of conformity, and the technical documentation, line by line, and record each comparison with a pass, a fail, or a query. The finding record, corrective action plan, and recheck log for the check should include the date, the sample identifier, and the version of each document compared. A market surveillance checker finding a wrong capacity label on a batch should keep failed checks on file with the corrective action, the new artwork or record version, and the recheck date. Market surveillance authorities can require corrective action, withdrawal, or recall under Regulation (EU) 2019/1020, and the operator record should show cooperation, the measures taken, and the dates, without overstating the outcome of a pending case.

How is one marking defect traced through a batch?

Tracing a defect through a batch starts with the finding: the model, the artwork version, the defect, and the date found. The production log is then checked for every battery marked with that artwork version, and the identifiers are listed. A worked trace for a wrong capacity label shows the artwork version, the production dates, the identifiers affected, and the stock status of each identifier: in stock, dispatched, or in the field. Each identifier receives a disposition: relabel, withdraw, or correct in the field, with a date and an owner. The trace closes only when every identifier has a disposition and a recheck, and the artwork version that caused the defect is withdrawn from production.

A defect is closed only by a recheck of the corrected marking, and a correction plan without a recheck date leaves the batch in doubt.